September 16, 2013
In summary, the SEC’s proposed rule changes would be detrimental to competition, efficiency, and capital formation for our members as well as cities, counties, and other municipal entities. We do not believe additional changes to money fund regulation are needed at this time. If further changes are adopted, however, we urge the Commission to (a) include a comment that it is not the SEC’s intent to promulgate changes to LGIPs, and (b) create an exemption for municipal money funds equivalent to that established for U.S. Government MMFs under the proposal. As State Treasurers concerned about the financial strength and integrity of states and all governmental units within our states, we appreciate this opportunity to offer our views on this matter.